The proposal, published Nov. 5 in the Federal Register, is seen helping inspectors verify the experience of applicants who only work part time as aviation mechanics.

AOPA wants to make sure that any policy change does not disqualify mechanics who only specialize in working on older aircraft. It is their unique expertise that ensures the safety of flight. Also, part-time mechanics are often the sole source of maintenance support for aircraft based at smaller airports.

In proposing the revision, the FAA acknowledged that a longstanding requirement for an IA applicant to be “actively engaged” as an A&P mechanic has been inconsistently applied.

For part-time mechanics, showing active engagement has been a vague process because the term has no specific regulatory definition, and the FAA’s own definition “has varied over time.”

Making matters worse, the FAA said, were past attempts at remedies that generated widespread confusion among inspectors and maintenance personnel.

The most recent effort was a clarifying memo sent out in 1988. It was rescinded last April.

The new draft language includes this passage: “The ASI will evaluate the scope of part-time or occasional activity based on the type of maintenance activity, including any special expertise required, and the quantity of maintenance activity performed.” The applicant would supply documentation.

The new proposal also provides a “carve out” provision designed to protect FAA inspectors who hold IAs from losing their inspection authority because of ethical constraints on their ability to perform inspections. The changes would be enacted as amendments to FAA Order 8900.1, Volume 5, Chapter 5.

AOPA is scrutinizing the proposal for its impact on A&P mechanics approaching time to renew their IA.